Corporate Tax - 2024 Virtual Conference

Introduction

Chaired by Pete Miller, this annual live broadcast conference with a panel of leading experts offers a comprehensive update as to the current hot topics in this fast-moving area.

Each session will provide a full opportunity for questions and answers.

Conference Agenda

This live and interactive 5 hour conference will cover the following:

10:00am-11:00am: Employee Ownership: What is it good for?

Chair: Pete Miller, Jerroms Miller

The evidence suggests that employee owned businesses achieve higher productivity and greater levels of innovation and are more resilient to economic turbulence. They also have more engaged, more fulfilled, and less stressed workforces. FA 2014 introduced a relief from capital gains tox for sales of shares to employee ownership trusts. Why did this happen? How do you qualify for relief? And is it all too good to be true?

This session will cover:

• The policy background
• The reliefs
• Qualifying conditions
• Disqualifying events
• Proposed Changes to include the latest on EOTs

Morning Break

11:10am-12:10pm: MBOs - Current Issues

Nick Wright, Jerroms Miller

Management buyouts are a tried and tested method of passing on ownership of a business to an existing or incoming management team.

However, in recent times we have witnessed HMRC’s changing stance on providing clearances on these transactions depending on the nature of the deal.

The session will cover the main issues we have encountered in obtaining clearance, such as:

• Drafting a strong commercial rationale to support the transaction
• Utilising personal investment companies for tax efficiency purposes
• The effect of an MBO on existing EMI option schemes
• Application of transactions in securities rules
• Stamp duty issues arising from MBO transactions
• Accounting for MBOs

12:10pm-1:10pm: W&I Insurance Backed M&A Deals -- Tax

Fionnuala Lynch, McCarthy Denning

Warranty and Indemnity Insurance (W&I Insurance) backed M&A deals are now standard and this session will cover how W&I insurance is used to cover tax risk in M&A deals.

The session will include:

• The interaction of a typical tax deed with the W&I policy
• The impact on the tax warranties
• How to negotiate the tax section of the W&I policy

Break for lunch

2:00pm-3:00pm: Corporate Debt in a Time of Recession

Philip Ridgway, Temple Tax Chambers

This session will cover:

• A recap of the normal rules
• The corporate rescue exemption
• Connected parties
• Becoming connected
• Substantial modifications

Afternoon break

3:15pm-4:15pm: Main Purpose Tests: What Recent Cases Tell Us

Sarah Squires, Old Square Tax Chambers

Various tax provisions now include main purpose tests and over the last year judges have had to consider the application of this test across various regimes (such as loan relationships, roll over relief and transaction in securities).

This session will cover:

• Recent cases (Euromoney, Kwikfit and Allam)
• How the main purpose test is likely to apply in practice

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.